OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

January 4, 1999

Mr. Stephen P. Wolf, CIH, CSP, CHMM
Corporate Industrial Hygienist
Akzo Nobel Chemical
300 South Riverside Plaza
Chicago, Ill 60606

Dear Mr. Wolf:

This is in response to your letter dated September 1, addressed to the Occupational Safety and Health Administration's (OSHA's) Office of Health Compliance Assistance (OHCA). In your letter you requested that OSHA review your respirator questionnaire. Unfortunately, we do not approve questionnaires. However, we can provide you with some guidance regarding what we expect in a modified form.

In your letter you stated that you have slightly reworded some questions to allow for a scannable format. The medical questionnaire does not have to be in the same format as Appendix C. The form can be converted to a scannable format, as you have done with yours. The employee in this case will fill in a circle with a No. 2 pencil next to the appropriate "Yes" or "No" rather than a circle around the word "Yes" or "No" as presented in the Appendix. Some of the questions in Section 1 of Part A can be reworded to get the same information. Question 3 can be reworded to ask for an employee's date of birth rather that his or her age (to nearest year). Question 5 can ask for height in inches, rather than feet and inches.

The questions in Part A. Section 2 are Mandatory, if the form is to be the sole basis for evaluating an employee's ability to use a respirator. All questions must be asked and each worded in the same manner as the Appendix in any form that is generated by the employer or a third party. The order of the questions can be changed and additional questions can be asked, if the Physician or other Licensed Health Care Practitioner (PLCHP) feels that these additional questions will help to determine an employee's ability to wear a respirator.

Please note that the Appendix as originally published had several typographical errors and omissions. Some of these were corrected in the Federal Register in April and several others will be corrected in a future Federal Register. These changes have already been incorporated in the "Questions and Answers on the Respiratory Protection Standard" document which we put up on our website in August. We have enclosed a copy of the revised questionnaire in both English and Spanish for your convenience.

In some companies all employees receive a physical examination by the PLCHP. In this case a medical questionnaire is not even required. Forms which are intended to gather an employee's medical history prior to receiving a physical examination by a PLCHP, may be designed to suit the PLCHP and do not have to follow Appendix C. Any information not included in the form can be gathered by the PLCHP during the examination.

I hope this answers any questions you may have about the requirements which must be met for any revised medical questionnaires. If you have any further questions you may contact OSHA's Office of Health Compliance Assistance at (202) 693-2190.

Sincerely,

Richard E. Fairfax
Director
Directorate of Compliance Programs